Comments and Response Report As Part of the Basic Assessment for The

Comments and Response Report as part of the Basic Assessment for the proposed Skukuza Safari Lodge development and associated infrastructure in Skukuza, Kruger National Park

Technical Report: E-R-2015-03-17-1 Prepared for: SANParks Prepared by: Exigo Sustainability (Pty) Ltd (Exigo)

Comments and Response Report as part of the Basic Assessment for the proposed Skukuza Safari Lodge development and associated infrastructure in Skukuza, Kruger National Park

17 March 2015

Conducted on behalf of: SANParks

Compiled by: H Gildenhuys R Kruger

REPORT DISTRIBUTION LIST

Name Institution Tracy-Lee Petersen Kruger National Park Blake Schraader SANParks Annemi van Jaarsveld SANParks Government Departments See table Registered parties See table

DOCUMENT HISTORY

Report no Date Version Status E-R-2014-11-07 7 November 2014 1.0 Draft for comment E-R-2015-03-17-01 17 March 2015 2.0 Final for comment

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Skukuza Safari Lodge: CRR Table of contents 1. INTRODUCTION ...... 1 2. PROCESS FOLLOWED ...... 1 2.1. NEWSPAPER ADVERTISEMENT ...... 1 2.2. SITE NOTICE ...... 1 2.3. DIRECT NOTIFICATION OF IDENTIFIED I&AP’S ...... 4 2.4. PUBLIC MEETINGS ...... 4 2.5. DRAFT BASIC ASSESSMENT REPORT ...... 5 2.6. FINAL BASIC ASSESSMENT REPORT ...... 5 2.7. SANPARKS NOTIFICATIONS NOT FORMING PART OF THE FORMAL BASIC ASSESSMENT PROCESS ...... 5 3. KEY COMMENTS ...... 6 4. COMMENTS AND RESPONSE REPORT ...... 7 5. CONCLUSIONS ...... 40

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Skukuza Safari Lodge: CRR List of Tables

Table 1 Comments and Response report ...... 8

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1. INTRODUCTION Public Participation is one of the most important aspects of the environmental authorisation process. This stems from the requirement that people have the right to be informed about potential decisions that may affect them and that they must be afforded an opportunity to influence those decisions. Effective public participation also improves the ability of the competent authority to make informed decisions and result in improved decision-making as the views of all parties are considered.

The Public Participation Process:

• Provides an opportunity for interested and affected parties (I&AP) to obtain clear, accurate and comprehensive information about the proposed activity, its alternatives or the decisions and the environmental impacts thereof; • Provides I&AP with an opportunity to indicate their viewpoints, issues and concerns regarding the activity, alternatives and/or the decisions; • Provides I&AP with the opportunity of suggesting ways of avoiding, reducing or mitigating negative impacts of an activity and for enhancing positive impacts; • Enables an applicant to incorporate the needs, preferences and values of the affected parties into the activity; • Provides opportunities to avoid and resolve disputes and reconcile conflicting interests; • Enhance transparency and accountability in decision – making.

Public Participation therefore allows interested and affected parties the opportunity to give their viewpoints and influence the process and the decisions of the competent authority.

2. PROCESS FOLLOWED

The following process was undertaken to facilitate the public participation for the proposed project:

2.1. NEWSPAPER ADVERTISEMENT

Advertisements, notifying the public of the Environmental Authorisation application process and requesting I&AP’s to register their comments with Exigo, were placed in in the Lowvelder on the 3rd of October 2014 and in the Phalaborwa Herald on the 10 th of October 2014.

2.2. SITE NOTICE

In order to inform visitors to the Kruger National Park, Skukuza rest camp and the Kruger Park employees of the proposed development, notice boards (in accordance with regulation 54(2)(a) and 54(3) of the EIA Regulations) were erected at the following places on the 1st and 2 nd of October 2014 (Refer to Figure 1 for a map indicating the locations):

Placement Size On the proposed Lodge site A2 Skukuza Conference Centre A2 Staff Shop in the living quarters (Albasini Shop) A2

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Skukuza Safari Lodge: CRR Skukuza Golf course club house A2

Phabeni Gate A3 Kruger Gate A3 Skukuza Rest Camp Reception A3 Skukuza Staff Village recreational area (at the pool, tennis court).) A2 SANParks Head Office Pretoria (reservation and wild card reception area) A3

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Figure 1: Location of notices placed in Skukuza Rest Camp and Village.

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2.3. DIRECT NOTIFICATION OF IDENTIFIED I&AP’S

Key stakeholders, who included the following sectors, were directly informed of the proposed development (Please refer to table for full list):

• The owners and occupiers of land adjacent to the proposed route alignment where the activity is or is to be undertaken or to any alternative site; • Surrounding lodges and developments around Kruger Gate; • Ehlanzeni District Municipality; • Mbombela Local Municipality; • Bushbuckridge Local Municipality; • Nkomazi Local Municipality; • Mpumalanga Department of Agriculture, Rural Development, Land and Environmental Affairs (DARDLEA); • Department of Water and Sanitation; • Department of Agriculture, Forestry and Fisheries; • Mpumalanga Department of Agriculture, Rural Development and Land Administration (DARDLA); • Department of Agriculture and Rural Development • Mpumalanga Department of Public Works, Roads and Transport • South African National Roads Agency Limited (SANRAL) • South African Heritage Resources Agency (SAHRA) • Mpumalanga Provincial Heritage Resource Authority • Mpumalanga Tourism and Parks Agency • ESKOM; • Various NGO’s and Conservancies

Please note that Public Participation process was started during the initial registration period for the project, and will extend to the Basic Environmental Impact Assessment (Basic Assessment) Phase. A final Comments and Response Report, detailing all comments from the I&APs will be included in the Final Basic Assessment Report (BAR).

2.4. PUBLIC MEETINGS The following meetings were held during the comment phase of the Draft Basic Assessment Report:

Date Time Location

Saturday, 29 November 2014 10h00 SANParks Boardroom, Groenkloof, Pretoria

Saturday, 10 January 2015 11h00 Skukuza Conference Centre

The relevant dates and times of the meetings were communicated to I&APs when they were notified of the availability of the Draft BAR on the 12 th of November 2014.

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Skukuza Safari Lodge: CRR 2.5. DRAFT BASIC ASSESSMENT REPORT

The EIA Regulations specify that I&AP’s must have an opportunity to verify that their issues have been captured. A period of more than 30 days (12 November 2014 to 15 January 2015) was made available for public comment on the Draft Basic Assessment Report (BAR) as part of the environmental impact assessment process. The availability of the Draft BAR was announced via personal notification letters to all the registered I&AP’s on the distribution list.

In addition, the Draft BAR was (and will be) distributed for comment as follows:

• Published on the SANParks website at http://www.sanparks.co.za/groups/eia_notices/ ;

• Electronic copies on request; and

• Hard copies will be made available on request.

2.6. FINAL BASIC ASSESSMENT REPORT

The EIA Regulations specify that I&AP’s must have an opportunity to verify that their issues have been captured. A period of more than 21 days will be made available for public comment on the Final Basic Assessment Report (BAR) as part of the environmental impact assessment process. The availability of the Final BAR was announced via personal notification letters to all the registered I&AP’s on the distribution list.

In addition, the Draft BAR was (and will be) distributed for comment as follows:

• Published on the SANParks website at http://www.sanparks.co.za/groups/eia_notices/;

• Electronic copies on request; and

• Hard copies will be made available on request.

2.7. SANPARKS NOTIFICATIONS NOT FORMING PART OF THE FORMAL BASIC ASSESSMENT PROCESS

The list below was not part of the formal notification process for the BAR; however members of the public and the media were also notified about the proposed project by means of a media briefing, newspapers and social media as described below.

SANParks held a media briefing on the 29 th of September 2014 to announce the project to the media. The media briefing was also posted on SANParks website on the 29 th of September 2014. SANParks provided the details of their Acting Head of Communications (Reynold Thakhuli) in the statement and mentioned that he could be contact for more information regarding the project. Interested parties that contacted Mr. Thakhuli regarding the project and wanted to be registered as an I&AP (during the registration period) were provided with Exigo’s details in order to be registered on the project.

The following articles/broadcastings regarding the development were relayed by various media: 1. Radio media:

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Skukuza Safari Lodge: CRR • Radio sonder grense (RSG) – Interview with SANParks – 1 October 2014

• Jacaranda 94.2 - Interview with SANParks – 1 October 2014 2. Newspapers/Electronic news:

• Beeld – “Kruger kry Lodge”– 30 September 2014

• Pretoria News – “Have your say on new Kruger Park Lodge – Public Participation opens on planned R238m facility” – 30 September 2014

• Media 24 – “Skukuza Safari Lodge: SANParks invites public to comment” – 30 September 2014

• GPS news – “KNP Lodge public participation opens”– 29 September 2014

• Lowvelder – “Public can now have their say on proposed lodge in Skukuza” – 30 September 2014

• Travelbuyer – “SANParks to build conference accommodation at Skukuza” – 1 October 2014

• My Lowveld – “Skukuza Safari Lodge public participation opens” – 30 September 2014

• Tourism update – “SANParks opens public participation for Skukuza Safari Lodge” – 30 September 2014 3. Social media:

• SANParks newsfeed – 1 October 2014

• SANParks Facebook page – 1 October 2014

• SANParks Wild Newsletter, E-news and Wild Magazine to 143,000 members

I&APs that contacted Exigo with regards to this development were all registered on the project.

3. KEY COMMENTS

Assessing the comments/concerns received during the public participation process, it is evident that the main points raised are:

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Skukuza Safari Lodge: CRR o Impact on the Stevenson Hamilton baobabs • Socio-Economic impacts o Need for this type of development o Local employment benefits o Availability of bursaries and learnerships o Local décor and art should be used at the lodge in order to benefit local artists • Water use optimisation o Grey water usage o Monitoring water abstraction from the Sabie River • Other o Waste minimisation strategies o Electricity minimisation options o Increased environmental destruction and increased pollution including chemical pollution, combustion fumes and oil spills on roads. o The EMP should be more stringent on the Applicant. o Reference should be made to the 20 Principles from the National Environmental Management Act (NEMA). o Concerns regarding over-commercialization and further lodges being built in the park.

These concerns have been documented here, answers provided where appropriate and those impacts requiring assessment have been undertaken and provided to the I&APS for review. Appropriate mitigation measures to address impacts were included in the BAR and EMPr.

4. COMMENTS AND RESPONSE REPORT

The following table forms the core of the Comments and Response Report as part of the Public Participation process for the project . It aims to provide a summary of the comments received. For detailed information about comments received, especially during public meetings, refer to the relevant meeting minutes.

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Table 1 Comments and Response report

Industry/Community/ Contact Details Notification Comments Response Organisation/Individual Municipalities Ehlanzeni District Adv. Hugh Mbatha Fax on 1 October 2014 No responses have been received by the end of the Municipality Municipal Manager – Fax did not go registration period PO Box 3333 through. Nelspruit Email sent on the 1 October 2014 1200 Tel: 013 759 8500 Fax: 013 755 8539 Email: [email protected] Municipal Health and Fax on 1 October 2014 No responses have been received by the end of the Environmental Management – Fax did not go registration period ST Shabangu through. Manager Email sent on 1 October PO Box 3333 2014 Nelspruit 1200 Tel: 013 759 8500 Fax: 013 755 8539 Email: [email protected] and [email protected] Mbombela Local Mr XC Mzobe Email on 1 October No responses have been received by the end of the Municipality Municipal Manager 2014 registration period PO Box 45 Nelspruit 1200 Tel: 013 759 2335

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Fax: 013 759 2070 [email protected] Mbombela Environmental Email on 1 October Mbombela LM registered as commenting Shile Mthembu 2014 authority. [email protected] A hard copy of the Draft BAR was delivered to the LM. Acknowledgement of receipt was received on the 14 th of November 2014. Mbombela Engineering Email on 1 October Jack Deville 2014 [email protected] Mbombela LM – Ward 39 Dudu Tryphinah Nkosi Sms on 1 October 2014 No responses have been received by the end of the Cell: 0834142499 registration period Mbombela LM – Ward 01 Madayisi Billity Mokoena Sms on 1 October 2014 No responses have been received by the end of the Cell: 076 873 8321 registration period Bushbuckridge Local Mr Doctor Shabangu Email and Fax on 1 No responses have been received by the end of the Municipality Municipal Manager October 2014 registration period Private Bag X9308 Bushbuckridge 1280 Tel: 013 799 1851/7 Fax: 013 799 1865 [email protected] Other parties at Bushbuckridge Email on 1 October No responses have been received by the end of the Municipality: 2014 registration period Emails: [email protected] ; [email protected] ; [email protected] ; [email protected] ;

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[email protected] Economic Development, Planning Fax on 1 October 2014 - No responses have been received by the end of the & Environment (EDPE) Successful registration period Mrs Sarah Mogakane Director Private Bag X9308 Bushbuckridge 1280 Tel: 013 799 1851/7 Fax: 013 799 1865 Nkomazi Local Municipality Mr MD Ngwenya Fax on 1 October 2014 - No responses have been received by the end of the Municipal Manager Successful registration period Private Bag X101 Malalane 1320 Tel: 013 790 0245 Fax: 013 790 0886 Nkomazi LM – Ward 7 Mathenjwa ND Sms on 1 October 2014 072 1143 065 Government Departments Mpumalanga Department Ms Robyn Luyt Email on 1 October Commenting authority – Requested to be updated Confirmed involvement on 1 October 2014 of Agriculture, Rural Cell: 082 672 7868 2014 and notified should a site visit with government be A hard copy of the Draft Development, Land and 30 Brown Street planned. Environmental Affairs BAR was delivered to [email protected] (DARDLEA) the DARDLEA. Department of Water and Mr F Guma Email on the 1 October No responses have been received by the end of the Sanitation (DWS) Chief Director: Mpumalanga 2014 registration period. Private Bag X11259 NELSPRUIT 1200 Tel: (013) 759 7310 Fax: (013) 759 7525 Cell: 081 030 9070 [email protected]

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Sampie Shabangu Email on the 1 October Registered as commenting authority Head of department 2014 [email protected] Forwarded on 2 October 2014 Case Official – Lebo Mosoa Email on the 2 October Registered as commenting authority Email: [email protected] 2014 A hard copy of the Draft BAR was delivered to the DWS.

Wietsche Roets Email on the 2 October Forwarded email to Mr. Shabangu Email: [email protected] 2014

Department of Agriculture, Mr Themba Khoza Email on 1 October Forestry and Fisheries Forestry Department 2014 – Email did not go through. Tel: 013 759 7494

[email protected] Dr N. Motete Email sent on 1 October No responses have been received by the end of the DDG: Forestry and Natural 2014 registration period Resources Management Tel: 012 309 5718 [email protected] Mpumalanga Department Ms. N.L. Sithole (Head of the Email on 1 October No responses have been received by the end of the of Agriculture, Rural Department) 2014 – Email failed registration period Development and Land Tel: 013 766 6020 Administration (DARDLA) [email protected] Mr. O.B. Magagula (Director: Email on 1 October No responses have been received by the end of the Ehlanzeni District - South) 2014 registration period Tel: (013) 759 4039 [email protected] Ms. P.N.Z Mpangane (Director: Email on 1 October No responses have been received by the end of the Ehlanzeni District - North) 2014 registration period Tel: 087 350 4955 [email protected]

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Department of Agriculture Mr. Love Email on 1 October No responses have been received by the end of the and Rural Development 31 Brown Street, Nelspruit 2014 registration period Tel: 013 754 0734 Email: [email protected] Ms Maureen Sithole, Email on 1 October No responses have been received by the end of the Private Bag X11219, Nelspruit 2014 registration period 1200. Tel. (013) 766 6068. Fax: 013-766 8429. E- mail: [email protected] Liaison: Mr Freddy Ngobe Email on 1 October No responses have been received by the end of the Tel. (013) 766 6086. 2014 registration period Fax: 013-766 8445. E-mail: [email protected] Mpumalanga Department MEC D.G. Mahlangu Fax on 1 October 2014 - No responses have been received by the end of the of Public Works, Roads and Private Bag X 11310 Successful registration period Transport Nelspruit 1200 Tel: 013 766 6978/9 Fax: 013 766 8471 SANRAL Northern Region Fax on 1 October 2014 - No responses have been received by the end of the Private Bag X17 Successful registration period Lynnwood Ridge 0040 Tel: 012 426 6200 Fax: 012 348 1512 Eskom Northern Region Fax on 1 October 2014 - No responses have been received by the end of the PO Box 1091 Johannesburg 2001 Successful registration period Fax: 0136933886 SAHRA SAHRIS Case ID: 6520 Loaded on 2 October No response received to date. http://www.sahra.org.za/cases/saf 2014 ari-lodge-and-associated- infrastructure-skukuza-kruger- national-park

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Mpumalanga Provincial Mr Benjamin Moduka Email on 1 October No responses have been received by the end of the Heritage Resource Cultural Officer (Acting Manager) 2014 registration period Authority 7 Government Boulevard Riverside Park Nelspruit Tel: 013 766 5196 [email protected] Mpumalanga Tourism and Private Bag X 11338 Email on 1 October No responses have been received by the end of the Parks Agency Nelspruit 2014 registration period 1200 Tel : +27 (0)13 759 5300/01 Fax : +27 (0)13 755 3928 [email protected] Johan Eksteen [email protected] Conservancies Kruger2Canyons Biosphere PO Box 408 Email on 1 October No responses have been received by the end of the Reserve HOEDSPRUIT 2014 registration period 1380 Cell: 082 551 7261 [email protected] SA Tourism Mr Brian Whittaker Email on 1 October No responses have been received by the end of the Chairperson 2014 registration period Private Bag X10012 Sandton 2146 South Africa Tel: 011 895 3000 Fax: 011 895 3001 [email protected] Birdlife SA P O Box 515 Email on 1 October Request for registration on 2 October 2014 Registered on 2 October 2014 Randburg 2014 2125 Tel: 011 789 1122 Fax: 011 789 5188 [email protected]

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Simon Gear – Policy and Advocacy Manager [email protected] [email protected] [email protected] [email protected] Kruger Park Protea Hotel Francois Email on 1 October No responses have been received by the end of the [email protected] 2014 registration period Sabi Park Ernst van der Merwe Email sent on 1 October No responses have been received by the end of the [email protected] 2014 registration period Sabi Sands Game Reserve [email protected] Email on 1 October Requested registration on the 17 th of November Registered on the 17 th of November 2014 and the a 2014 2014. EAP provide the communication on the review and Tel: 087 820 0807 public meeting.

Edwin Pierce Ecologist [email protected] Burchell’s Bush Lodge Dave Email on 1 October No responses have been received by the end of the [email protected] 2014 registration period Lukimbi Safari Lodge Sean Smith Email on 1 October No responses have been received by the end of the [email protected] 2014 registration period Lion Sands Izak De Villiers Email on 1 October Request for registration on 3 October 2014. Registered on 3 October 2014. Email: [email protected] 2014 Additional comment: 1. Potential for nuisance The following design measures were built into the Andrew Rossaak – Emross 2. Noise and Light pollution design of the lodge in order to limit the impact Consulting (nuisance, noise and light pollution) on the [email protected] surroundings:

[email protected] • The design is fragmented – a collection of [email protected] smaller structures. • The design inverts the bedroom wings to central landscaped atriums – contain noise and light internally. • Public areas (dining room, bars, outside lounges, gym and lap pool are centralised between the bedroom wings – contain noise

and light internally. • Back-of-house situated on the opposite side of the lodge, away from existing tourist

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accommodation. • All lodge deliveries and staff access will be from the back. • Thatch canopies to the bedroom wing’s

external walkways – blend in with existing thatched structures. • Bus and concession parking will be away from the lodge. • Lodge design incorporates the use of natural materials and earthy colours • Walls to screen the drop-off area from the existing tourist accommodation – minimise

sight, sound and light from this zone.

According to the Visual Impact Assessment (refer to Appendix D), through implementation of strict mitigation measures the lodge will have a Moderately Negative Visual Impact during the Construction Phase, while during the Operational

Phase the lodge will have a Low Negative Impact.

Mitigation measures include, amongst others, the strategic planting of tree and shrub screens, as well as a fence between the lodge and the rest of the camp. The resultant landscape would not be totally uncharacteristic when set within the attributes of the receiving visual environment. Through the implementation of mitigation

measures the visual impact expected by the additional infrastructure (e.g. housing units) is Low during the Construction Phase and Negligible during the Operational Phase. The resultant, landscape would not be uncharacteristic when set within the attributes of the receiving visual environment. Important to note is that the above impact

statements assume that management measures will be implemented effectively and managed in the long term. The recommended management

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measures were written into the Environmental Management Programme (EMPr). The EMPr is to act as a flexible, stand-alone document and must be implemented during all phases of the

development and throughout the lifespan of the proposed activities.

For more information refer to the Visual Impact Assessment attached to Appendix D of the BAR. At the meeting on the 10th of January 2015: 3. Impact of lights at night and on the roads 3. An addendum to the Visual impact assessment was conducted and provided they drive with their guests within the to Lion sands for comment concession area to be evaluated as there is already an impact from Skukuza’s side. 4. 20 Principles on NEMA to be included in the 4. Principles have been discussed in BAR Appendix J5 of the BAR. 5. EMP to be more stringent (should vs must) 5. EMP updated 6. Attached to the EMP are the KNP plans 6. Nuisance animal management for nuisance animals. 7. Requested a meeting with Lion Sands - Hyenas and badgers – There is daily fence inspection to be executed by the Maintenance Officer to close any holes or repair the fence. Also cattle grids are installed at the entrance gates to the camps were these animals become a problem - Baboons and monkeys - All the camp fences have been electrified to prevent baboons entering a camp. KNP also installed baboon proof dustbins to limit access to food waste - Bat management plan attached to EMP

7. A meeting was proposed in Pretoria by the Applicant. The documents were

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instead provided for a 10 day review period before finalisation. Additionail measures proposed have been included in the EMP

Lion Sands – Sabi Sands Ronnie Borrageiro, Email on 1 October Refer to Lion Sands above. Email: [email protected] 2014 Mala Mala Facsimile: + 27 11 442 2318 Email on 1 October No responses have been received by the end of the e-Mail: 2014 registration period. [email protected] Facsimile: + 27 13 735 3100 e-Mail: [email protected] Facsimile: + 27 13 735 9300 e-Mail: [email protected] Shishangeni Private Lodge Ms Liesl Breytenback Email on 1 October No responses have been received by the end of the Tel: 013 735 3300 2014 registration period Cell: 072 910 0931 [email protected] Jock Safari Lodge Mr Louis Strauss Email on 1 October No responses have been received by the end of the Tel: 013 735 5200 2014 registration period Cell:072 998 0243 [email protected] Tinga Private Game Glenda Ubisi Email on 1 October Refer to Lion sands above Reserve [email protected] , 2014 Nerina Sven Linstrom, Email on 1 October Refer to Lion sands above Email: [email protected] 2014 Rhino Walking Safaris Mr Gerrit Meyer Email on 1 October No responses have been received by the end of the Cell: 083 631 4956 2014 registration period [email protected] NGO’s Game Rangers Association Mr Andre Botha Email on 1 October Request for registration Registered on 1 October 2014 of Africa [email protected] 2014 Endangered Wildlife Trust: Scott Ronaldson The notification of the Bird of Prey Programme [email protected] draft BAR and meeting was sent on 12th of

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November 2014.. World Wide Fund for Ziyanda Mfanta Email on 1 October No responses have been received by the end of the Nature Tel: 012 888 2800 2014 registration period [email protected] Wildlife and Environment Mr Tony Ferrer Email on 1 October Society of SA (WESSA) [email protected] 2014 Mr Morgan Griffiths Email received on 30 Request for registration Registered and provided with BID on 1 October Governance Programme Manager September 2014 2014

The notification of the draft BAR and meeting was sent on 12th of November 2014.. Wildlife and Environment Dr. Simon Evered Email on 1 October Refer to WESSA registration above Society of SA (WESSA): E-mail: [email protected] 2014- failed Lowveld region PO Box 336, Kiepersol 1241 Tel: 013 750 0808 Fax: 011 507 5975 Other Hamiltons Mr Trevor Tod Email on 1 October No responses have been received by the end of the Tel: 013 790 3421 2014 registration period. Fax: +27 (0) 11 463 1489 [email protected] .za Kruger Park Times Lynette Strauss Email on 1 October No responses have been received by the end of the E-Mail: [email protected] 2014 registration period Siyabona Africa [email protected] Email on 1 October No responses have been received by the end of the 2014 registration period

Dr Salmon Joubert 014 743 2097 Email received on 30 Request for registration. Previously registered on 17 December 2013 and PO Box 1354 Naboomspruit 0560 September 2014 again registered and provided with BID on 1 [email protected] At the meeting on the 10 th of January 2015: October 2014. The notification of the 1. He voiced his appreciation for the 1. Noted draft BAR and meeting opportunity to comment 2. GP stated that SANParks is aware that was sent on 12th of 2. Commercialisation vs conservation – they need to keep Wilderness areas, but November 2014. Conservation should be the main focus in doing so there will be areas that they 3. The saturation point for visitors needs to need to sacrifice in order to allow them to keep the wilderness areas. He also

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be determined. added that they need to be careful of 4. Do SANParks specifically target how they do this. He explained that in government conferences, and will the this regard there are expansion activities suites in the lodge also specifically cater currently taking place. for those that require more upper 3. Noted market (luxury) accommodation (are the 4. There are 8 Luxury suites. suites all the same)? 5. Noted 5. He is concerned that the current market 6. Noted. In order to be registered on might not visit the park anymore. SANParks draft documents out for public 6. He asked to be placed on the notification comment, I&APs can register on database on park consultation (e.g. SANParks’ website at the following link: zonation discussions). http://www.sanparks.co.za/assets/docs/ conservation/park_man/pmp- stakeholder-participation.pdf

Gerhard Smit [email protected] Telephonic discussion Requested info around the conference facility in Previously registered on 27 February 2013 and on 30 September 2014 Feb to November 2013. AGES placed Mr. Smit in again registered and provided with BID on 1 contact with Sivest and registered Mr. Smit. October 2014. The notification of the nd draft BAR and meeting nd Comments confirmed on the 2 of October 2014. was sent on 12 th of Comments received on the 2 of October 2014: Previously registered on 27 February 2013 and November 2014 1. What times will access to the lodge be again registered and provided with BID on 1 allowed (gate times or 24 hours per day) October 2014. 2. The market research showing the need nd for this type of development Comments confirmed on the 2 of October 2014. 3. On the 16th of November Mr Smit 1. The aim is that the current park rules to visitors are maintained i.e. normal gate hours. notified the EAP that his email address is The park rules in this regard are provided on incorrect on the reports. the SANParks website: http://www.sanparks.org/parks/kruger/get_th ere/gates.php. 2. Various research has been concluded, some by SA Tourism, Universities and internally. Internal surveys to our current customer base (mainly conducted by UNW) do indicate that a

lodge is not required and that the current visitor base are happy staying with the current self-catering options, however, from a

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business perspective, with occupancies of 88% in Skukuza, additional accommodation is required. As part of our Responsible Tourism Strategy 2022, product diversification is a key

component

3. The email address was corrected and the updated document uploaded on the 17 th of November 2014 and SANParks’ website.

The following is a summary of comments received at the meeting on the 29 th of November 2014 and A detailed response was provided to Mr Smit in a letter provided to him via email on the 16 th of letter received at and after the meeting: March. The response below serves as a brief 4. He asked for the Traffic study to be summary: updated to reflect the impact on game viewing roads. 4. The Annexure to the Traffic study was 5. He requested a follow up meeting to be provided for comment to Mr Smit on 2 March held on outstanding issues. 2015. 5. A request for a follow up meeting on the 11 th 6. Past information as not provided and of February 2015 was sent to Mr Smit on the they that had to pay for the information. rd 3 of February 2015. Mr. Smit however 7. SANParks pride themselves in their contacted the EAP on the 4 th of February 2015 transparency and honesty. and stated that he doesn’t see the need for a 8. Which SANParks Department handles meeting if they provide him with answers to the tourism and development planning his questions and the updated traffic study. for SANParks? 6. SANParks have provided the information at a cost due to the vast amount of printing 9. When the need for a lodge was realised required. in Skukuza When was the decision made 7. Noted to plan a lodge? 8. The SANParks team present at the public 10. Who will operate the lodge? meetings provide input to the Board for 11. For how long will SANParks operate the decisions lodge planned? 9. The need for a lodge was realised while 12. Are there plans to privatise the Lodge construction of the Conference facility was taking place. SANParks have also received operations? requests for accommodation when bookings 13. What is the expected annual were received and enquiries are made for return/profit from the Skukuza Lodge? conferences.

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14. What is the current utilization of the 10. SANParks are planning to operate the lodge. Skukuza Conference Centre? This will be done together with the conference 15. What is the breakdown of the users of facility. 11. Unknown at this stage. the conference centre? 12. Might be looked at in future but not currently 16. By what percentage do you expect to planned. increase the conference centre 13. Approximately R8 million from year 5. utilization rate once the Skukuza lodge is 14. Approximately 20 conferences per year and 35 in operation? SANParks meetings. The reason for such is that 17. Do SANParks have any scientific surveys the Skukuza Rest camp runs at 88% occupancy which indicate a need for lodges/hotels and hence there is no accommodation for the required conferences in the KNP? 15. Current breakdown is 75% private companies 18. Is the Lodge SANParks are planning really and 25% government organisations what visitors to our National Park expect 16. It is anticipated that the usage of the to find? conference facility will increase significantly to 19. Did you consider the opinion of the medium or high with the operation of the visitors to our National Parks in your lodge. 17. Various research studies have been concluded, planning of hotels/lodges? some by SA Tourism, Universities and 20. Expressed the opinion that the vast internally. Internal surveys to SANPark’s majority of comments towards these current customer base do indicate that a lodge plans are negative. is not required and that the current visitor 21. Where in the BAR for the Skukuza base are happy staying with the current self- conference centre was the need for a catering options, however, from a business hotel or lodge mentioned? perspective, with occupancies of 88% in Skukuza, additional accommodation is 22. What is the expected break even required. As part of SANPark’s Responsible occupancy rate for the Skukuza Lodge? Tourism Strategy 2022, product diversification 23. What will the gate access times be for (attracting different and future emerging the Skukuza Lodge? markets) is a key component. 24. What happens when visitors to the lodge 18. Refer to answer directly above. arrive at the Park entrance after closing 19. The planning documents are placed out for or need to leave before they open public review and notifications are placed on the SANParks website. The environmental 25. Why are the planned access times to the impact assessments for the proposed projects Skukuza Lodge different from those of also have their own public participation as part the proposed Malelane tented camp of the National Environmental Management

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26. Who will transport the staff of the Act (Act 107 of 1998) (NEMA) processes. Skukuza Lodge to and from the Lodge? 20. Noted. Please refer to all comments within 27. Will the possible approval of the plans this document. 21. The Skukuza Conference Centre BAR mentions for the Skukuza lodge set a precedent for the potential need for further accommodation more hotels/lodges in the KNP? and the potential cumulative tourism impact 28. He stated that the proposed associated with this on page 33 of the report. development will lead to increased 22. 53% violation to Park Rules, an increase in the 23. Refer to answer no 1 above. potential for poachers and other 24. Refer to no 1 criminals to lose themselves in the 25. The operations are different from each other (one will be operate as a private concession crowd, increased chemical pollution, and the other by SANParks) combustion fumes and oil spills on roads, 26. Will be transported by SANParks staff bus. an increase in the visual impact, 27. Only the two lodges are planned – refer to the increased environmental destruction and IDP projects attached to Appendix J6 of the an increase in the amount of road kills to BAR (Basic Assessment Report). Also refer to animals by shuttle vehicles. the section in the Basic Assessment Report where this is addressed (Section 10 – Activity 29. A study by UNISA in 2004 already Motivation). showed over-utilisation in the southern 28. Noted. Various specialist studies in this regard (Marula) region. have been undertaken and mitigation 30. Do SANParks expect of the appointed measures proposed. The increase in traffic consultants to get approval for the (comments received related to the violation of project? park rules, potential for poachers to lose 31. Where will the funds for the lodge be themselves in the crowd, pollution on roads, road kill) is addressed in the Traffic Impact derived and what happens if Assessment. Visual, light and noise pollution is overspending occurs? addressed in the Visual Impact Assessment 32. When will the project be put to tender and/or mitigation measures in the EMP. and when do you expect the tenders to Human pollution and environmental be awarded? destruction (significance and mitigation) is 33. How many hotels/lodges with amenities addressed in the impact assessment and EMP. similar to the ones planned for Skukuza 29. KNP have included most of the recommendations as listed in this article in and Malelane, are SANParks planning for their medium and long term management the KNP and also over what period strategies in Kruger – to name a few; 34. Due to the shallow root system of a. KNP introduced restrictions on specific roads

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baobabs; is the best option to preserve as far back as 2005 – see media release and the Stevenson Hamilton baobabs or to article attached to the letter to Mr Smit. rather move them? Will they survive in b. KNP have introduced one way roads in specific loops and two spoor tracks and will the atriums? continue implementing this principle on new 35. Do SANParks still conform to the IUCN proposed loops. principles for National Parks? How do the c. KNP have not decided to tar more roads in hotels/lodges fit in with the IUCN the south, but are investigating suitable soil principles? stabilizers to reduce the gravel loss on gravel 36. Was a Strategic Environmental roads and that include bitumen, chemical Assessment conducted and where can a and other enzyme products. d. KNP are busy introducing more one way two copy of this document be obtained? spoor loops and rustic viewing points and 37. SANParks should review their bird-hides to get more tourists of the main commercialization plans and rather build roads for longer periods. outside of the park. e. KNP are considering more rustic picnic spots. f. KNP have started to move the day visitor facilities from inside the rest camps to a new location outside the camp – some of the camps completed are Berg en Dal,

Pretoriuskop, Skukuza, Letaba and Shingwedzi. KNP are reviewing the effectiveness of these day visitor sites and the products that are offered at these sites. 30. The environmental consultants were appointed as independent Environmental Assessment Practitioners (EAPs) in order to assess the impact on the environment and

submit reports to the Department of Environmental Affairs (DEA). The EAPs has no authority in making a decision in this regard. The decision (approval or rejection of the project) is taken by the DEA. Payment to the EAP is related to a professional service that is provided and does not relate to whether the

project is approved or not.

31. R240mil is received from the state. The proposed infrastructure will come from state

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funded money and the revenue derived from it will go to SANParks. The budget is being managed by a professional team appointed in this regard.

32. If all goes to plan and SANParks receive approval mid-2015, the plan is to go to tender during the latter half of 2015 and to open the lodge in mid-2017. 33. None. Only Skukuza and Malelane – refer to list of IDP projects attached to the letter to Mr. Smit (also attached as Appendix J6 of the BAR).

34. We have consulted with various botanists and the atriums are deemed to be suitable habitat for the baobabs considering the space surrounding the trees as well as the planned landscaping surrounding the trees (even over decades it is not anticipated that the tree roots will impact on surrounding buildings). The roots system is indeed shallow; although

they are growing in close proximity to buildings at this stage as well. The thicker and exposed roots are closer to the tree, while smaller, softer roots grow further away from the main tree stem. The trees are also currently growing in a higher rainfall area than the typical climate of the north of KNP,

therefore the root system are not expected to cause any problems. Given the dimensions of the atria they should be well accommodated. In terms of damage to the roots, elephants regularly dig up huge sections of roots from wild trees and they cope without any problem. Given the shallow and extensive root systems, the construction team might encounter the

roots as they are digging for foundations for the lodge. Experience from the Skukuza Airport construction has shown that these can

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be easily accommodated by bridges through the foundations which allows for the roots to persist and grow (the construction team had to do this for the Marula trees). Baobabs are

extremely hardy and adaptable and cope with far more significant pressures in the veld than what they currently experience in the camp now or later when the lodge is constructed. As recommended in the reports, the trees and larger exposed roots in close proximity to the trees (within the tree canopy) should be fenced off and protected at all cost during

construction. 35. Yes – please refer to the full response in the letter dated 13 March 2015. 36. A SEA has been done in 2009. A copy was On 2 March 2015 Mr Smit acknowledged receipt of provided to the I&AP. the Traffic Assessment Annexure provided (refer to 37. Noted right hand column) and stated that he does not The Annexure to the Traffic Impact Assessment to believe that the densities remained the same when address the impact on the game viewing roads the guests to the park increased by 17.03%. He were provided via email to Mr Smit on 2 March provided an extract from SANParks’ annual 2015. reports. He asked for proof of the assumption that 70% of visitors are day visitors and by whom the On 18 March 2015 a letter compiled by the EAP measurements were taken. was emailed to Mr Smit in which clarity regarding the data on which the Traffic study was based was provided. The traffic engineer stated that the study is based on the best traffic data available as contained in the Maroela Traffic Study (part of the Strategic Environmental Assessment). The data covers 24-hour 7 day traffic counts during both peak and off peak season periods as well as vehicle occupancy and drivers’ interviews. For traffic modeling purpose this data is the best data available and this way of collecting data forms the basis of traffic modeling and the calibration of a model. The model is used and expanded with

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traffic growth to determine the future 5, 10 and 20 year network requirements. Calibration is checked normally every 10 years and then adjusted if major differences occurred, then the process repeats itself. Traffic flow patterns and gate entry data is two completely different things from each other and you cannot compare the two directly. Traffic flow patterns indicate how many vehicles travel at what time during the day on the road, which direction they travel etc. This was for instance used to determine the density at the counting stations. In the KNP we would expect to have an early morning and late afternoon peak (game view peaks). This is however not the case. The peak occurs mid-morning and early afternoon which gate entry data does not show. We used the Maroela Traffic Study data as basis (calibration purpose) and the gate entry data for 2008-2012 to check the background growth and this is dealt with in the report. SANParks also provided clarity on the data used by mentioned that the figures quoted in the annual reports are average bed- and camp nights sold for the financial year and cannot be used to calculate the % split between day visitors and overnight visitors. A spreadsheet was provided to show that the ratio between day-visitors and over-night visitors are 72,2% day visitors and 27,8% over- night visitors and that this corresponds with the survey that was done during the Marula Traffic Study where a split of 70 % day visitors and 30% over-night visitors were calculated. The ratio as used by the Traffic Consultant would thus be accurate. Anton Smit PO Box 51601 Email on 1 October Requested info around the conference facility in Previously registered on 27 February 2013 and Wierda Park 2014 Feb to March 2013. AGES placed Mr. Smit in again registered and provided with BID on 1 0149 The notification of the contact with Sivest and registered Mr. Smit. October 2014. 012 660 1125 draft BAR and meeting Comments received on the 2 nd of October 2014.

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082 873 2298 was sent on 12 th of Fax: 086 677 8876 November 2014 Comments received on the 2 nd of October 2014: 1. SANParks acts on behalf of the State when [email protected] 1. Does the conference facility and will the building in a national park and is not required lodge have approved building plans and to apply and obtain prior written approval foundation designs by an approved engineer from the municipalities before erecting buildings in a park. SANParks remains however

obliged to comply with the national building regulations in respect of buildings in a national park. SANParks acting on behalf of the state needs to lodge the building plans and specifications with the municipality for its information and comment before commencement of construction of the building. 2. Market study done for the conference facility 2. Various research has been concluded, some by and lodge SA Tourism, Universities and internally. Internal surveys to our current customer base (mainly conducted by UNW) do indicate that a lodge is not required and that the current visitor base are happy staying with the current self-catering options, however, from a business perspective, with occupancies of 88%

in Skukuza, additional accommodation is required. As part of our Responsible Tourism Strategy 2022, product diversification is a key 3. Will access to the lodge be 24 hours a day or component. gate times. If so then this could pose threats 3. The aim is that the current park rules to regarding poaching, road kill etc. visitors are maintained i.e. normal gate hours. Exceptions will also be dealt with as per the current rules Lanette Smit 082 079 4779 Email on 1 October Request for registration Previously registered on 27 February 2013. [email protected] 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Fred de Groot [email protected] Email on 1 October Request for registration Previously registered on 4 March 2013 and again Africa Wild 2014 At the meeting on the 29th of November 2014 and registered on 9 October 2014.

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The notification of the comments received after the meeting: draft BAR and meeting 1. He stated that the rondavels will be 1. Mr de Groot was shown where the five th was sent on 12 of demolished that could generate an rondavels are proposed to be removed. November 2014 SANParks is currently not planning to income and wanted to know where will build the rondavels somewhere else as they be erected if they ever are needed. the lodge will cater for the lost 2. Is Col Stevenson Hamilton’s house near accommodation. the baobabs? 2. The archaeologist consultant on the 3. What mitigation will be taken should the project has done extensive site surveys building foundations be found during and has gone through archives at the construction? SANParks Groenkloof offices and the Skukuza library. All indications are that, 4. He stated that there are more hotels should the house have been close to the planned than what is being baobabs, it is not currently in existence communicated. anymore. The structures (houses) 5. Who applied for the changes to the currently on the site do not have any Environmental listed activities to relax heritage value. them for these developments. 3. Should remains and/or artefacts of 6. He stated that SANParks should rather fix heritage value be discovered on the the current accommodation than to site during earthworks, all work will construct more facilities as the park is cease in the area affected and the already too full. Contractor will immediately inform the Construction Manager. The Project manager will inform the Environmental Manager, ECO and South African Heritage Resources Agency (SAHRA). 4. No more hotels are planned - only Malelane and Skukuza. Refer to IDP list attached as Appendix J6 of the BAR. 5. Changes to legislation are not applied for by certain stakeholders. The Department takes various issues into account and also place the regulations on review prior to updating the listed activities. 6. Noted James Rawdon [email protected] Email on 1 October Request for registration Previously registered on 4 March 2013

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2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014. Adele Wright [email protected] Email on 1 October Request for registration Previously registered on 4 March 2013 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Douglas William Ellerbeck [email protected] Email on 1 October Request for registration Previously registered on 4 March 2013 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Ria Millburn 011 433 3670 Email on 1 October Request for registration Previously registered on 16 March 2013 2014 [email protected] The notification of the draft BAR and meeting was sent on 12 th of November 2014 Rita van Dyk [email protected] Email received on 29 Request for registration Registered and provided with BID on 1 October September 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Kim van Den Heever [email protected] Email received on 30 Request for registration Registered and provided with BID on 1 October (UNISA student) September 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Hylton Allison [email protected] Email received on 1 Request for registration Registered and provided with BID on 1 October October 2014 The notification of the

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draft BAR and meeting was sent on 12 th of November 2014 Henk Bredenoord [email protected] Email received on 1 Request for registration. Registered and provided with BID on 1 October. Premier Hotels and Resorts October 2014 Following comments received on the 15 th of The notification of the October 2014: draft BAR and meeting 1. Interest in involvement in Lodge and 1. Interest shown by Premier Hotels is been th was sent on 12 of Conference centre management noted. However, SANParks’ current plans are November 2014 to manage the lodge themselves, should a private operator be sought, a transparent

tender process would be undertaken to appoint such operator and Premier Hotels 2. Local employment would be welcome to participate. 2. These recommendations are noted. The aim during the construction and operational phases would be to make use of local 3. Bursaries and learnerships employment as far as possible. 4. Support local artist and buy local décor and 3. Noted. art 4. Local décor and art will be used where 5. Water use optimisation possible. 5. For the lodge, water will be re-used from all the shower and Wash Hand Basin water and

use that as a first priority for the water closet (flush toilet) flush and what is left (combined with rainwater harvesting when available) for

6. Grey water usage irrigation. 6. Same as 5 above. 7. Waste minimisation strategies 7. Waste will be separated at source (the lodge) and at the Skukuza central materials recycling facility. For detailed waste management measures refer to the EMPr. 8. Electricity minimisation options 8. The following measures are built into the design (refer to BAR and Concept design report): Solar panels • • Heat-reclaim for hot water generation

(summer) and high efficiency heat-pump systems for winter and make-up

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• Building layout and design as well as “occupancy-activated” aircons for cooling • Kitchens: will use gas equipment as far as practically possible, and use energy efficient equipment alternative

when/where available.

• Lighting: use energy efficient light fittings, movement sensor activation in bedroom passage ways, stairs and bathrooms

At the public meeting on 29 November 2015: Reply at the public meeting: 9. Wanted to know if there will be a back-up 9. The existing Skukuza generator still has enough capacity for the lodge as well. generator.

Graeme Sim [email protected] Email received on 1 Request for registration Registered and provided with BID on 1 October October 2014 2014. The notification of the draft BAR and meeting was sent on 12 th of November 2014 Sal Davies [email protected] Telephone conversation Requested more information. on the 2 October 2014 Registered on 2 October 2014. The notification of the draft BAR and meeting was sent on 12 th of November 2014 Susan Abell [email protected] Email received on 2 Request for registration on 2 October 2014 Registered on 2 October 2014. October 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Elise Tempelhoff [email protected] Telephone conversation Request for registration on 2 October 2014 Registered and provided with BID on 2 October Beeld on the 2 October 2014 2014. The notification of the draft BAR and meeting was sent on 12 th of

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November 2014 Jan du Plessis [email protected] Email received on 2 Request for more information and requested Provided with BID on 2 October. Information October 2014 whom can be contacted at SANParks with regards provided to SANParks to contact Mr. du Plessis to similar ventures The notification of the draft BAR and meeting was sent on 12 th of November 2014 Silvia Swoboda [email protected] Email received on 2 Request for registration on 2 October 2014. Registered on 3 October 2014. BID provided on 3 October 2014 Request for more information on 3 October 2014. October 2014. The notification of the Additional comment: draft BAR and meeting 1. Concern that project cost will be higher than 1. SANParks has engaged the services of a th was sent on 12 of initially planned Professional Quantity Surveyor to control November 2014 the costs relating to the project. As the design progresses from Concept Design to

Detailed Documentation, the accuracy of the Estimated Cost of the Lodge will improve. Currently there is a 5% contingency in the cost estimate to accommodate this. It is planned that the facility will be fully documented at the time of tender and that minimal provisional sums will be included in the Principal Building Tender to minimize

cost risk during construction. Ultimately the cost for the development will be established through market conditions at the time of construction as well as unforeseen items outside of the control of SANParks and the Consultant Team. More information can be provided should it be needed.

th th BAR report was emailed on the 13 of November Requested the BAR via email on the 12 of 2014. The EAP also stated that should any November 2014. appendices be required she will forward them. Tony Zoghby [email protected] Email received on 5 Request for registration on 5 October 2014 Registered on 7 October 2014 October 2014 The Requested the BAR or location of documents on notification of the draft the 17 th of November 2014. EAP provided the Draft BAR and also the location BAR and meeting was of documents on the SANParks website on the 17 th

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sent on 12 th of of November 2014 November 2014 Corrie Fourie [email protected] Email received on 7 Request for registration on 7 October 2014 Registered on 13 October 2014 October 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Friedemann Essrich [email protected] Email received on 7 Request for registration on 7 October 2014 Registered on 13 October 2014 October 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Theo Doms [email protected] Email received on 7 Request for registration on 7 October 2014 Registered on 13 October 2014 October 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Willem du Plessis [email protected] Email received on 7 Request for registration on 7 October 2014 Registered on 13 October 2014 October 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Plantago Lanceolata [email protected] Email received on 9 Offered their ecological and wetland services. Registered on 13 October 2014 Divhani Mulaudzi October 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Robert and Fiona Legg [email protected] Email received on 12 Request for registration on 12 October 2014 Registered on 13 October 2014 October 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014

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Elsabe Ras [email protected] Email received on 14 Request for registration on 14 October 2014 Registered on 14 October 2014 October 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Michael Wright [email protected] Email received on 15 Request for registration on 16 October 2014 Registered on 16 October 2014 and BID provided October 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Rufus Viljoen [email protected] Email received on 16 Request for registration on 16 October 2014 Registered on 16 October 2014 and BID provided [email protected] October 2014 The notification of the draft BAR and meeting was sent on 12 th of November 2014 Marthinus Christoffel [email protected] Email received on 29 Request for registration on 29 October 2014. Registered on 29 October 2014 Fourie October 2014 1. Mr Fourie is opposed to the development of 1. Noted The notification of the a lodge in Skukuza and states that it will have

draft BAR and meeting a negative impact on visitors to the park. was sent on 12 th of 2. Mr Fourie feels that the public consultation November 2014 2. Please refer to section 2 of this report for was inadequate. information on process followed by Exigo and SANParks to notify the public of the process. SANParks directed I&APS to Exigo where Exigo’s information was not provided directly.

th 3. On the 13 of November 2014 Mr. Fourie th 3. On the 13 of November 2014 the EAP was unhappy with the notification as he responded to Mr. Fourie quoting the letter sent thought he only had one day to comment on to I&APs to state that if the reports can’t be the report and that everyone cannot access accessed it can be provided in another method. the report on SANParks website. The EAP also asked him in which format he 4. On 24 November 2014 Mr. Fourie wanted to would like the reports. The EAP stated that the review period is until 14 January 2015 and not know who the Applicant is for the proposed until 14 November 2014.

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development for which Nu-Leaf is the EIA 4. On 24 November 2014 the EAP replied that consultant. He stated that Mr Glen Philips Radison Blu is the Applicant for the Malelane mentioned Malelane Safaris and Radisson development and that the only lodge development by SANParks is the Skukuza Safari Blu. He also enquired whom the authority is Lodge. The proposed development will need that will issue the ‘final’ authorization. authorization from the National Department of Environmental Affairs (DEA) and according to her understanding the draft reports for the Malelane Lodge is not yet available for comment. th Jurgens Wiedemann Jurgens.Weidemann@aurecongrou Email on the 13th of Request for registration on 13 th of November 2014. Registered on the 14 of November 2014 and the p.com November 2014 EAP provided the communication on the review and public meeting. th Liesl Koch [email protected] Email on the 16 th of Request for registration on 16 th of November 2014. Registered on the 17 of November 2014 and the November 2014 EAP provided the communication on the review and public meeting th Toulon Property and Wayne Boyd Email on the 17 th of Request for registration on 17 th of November 2014. Registered on the 17 of November 2014 and the Kirkmans Kamp [email protected] November 2014 EAP provided the following communication on the kirkmanslodgemanager@andbeyon review and public meeting. Mr Boyd also raised the following concerns on 17 d.com November 2015: 1. Please refer to the Annexure compiled to 1. Toulon property and Kirkmans Camp (within the Visual Impact Assessment. The Sabie Sands Game Reserve) are situated Annexure addresses the impact on the directly north of Skukuza and a large portion private concessions to the north of of the property has an elevated view down Skukuza. The report by the Visual Impact over Skukuza and there is a concern Assessor states: “The spatial distribution of the viewshed indicates that views regarding the light and noise impact on their from both the Tinga lodges and the Sabie guests game drive experience. Sands Reserve would not be affected by 2. The Toulon property is already impacted the lodge.” greatly by Skukuza and the surrounding KNP 2. Noted. Have been brought to the infrastructure. attention of SANParks and they are working on the issues raised in order to minimise the current visual impact from Skukuza (e.g. high masts within Living Quarters). Nigel Fernsby [email protected] Public meeting on the At the public meeting on the 29 th of November AIKONA member

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29 th of November 2014 2014 Mr Fernsby had the following comments: 1. The Annexure to the Traffic Assessment 1. Did the Traffic Impact Assessment look at the addressing the impact on game viewing possibility that one person might be attending roads are attached in Appendix D of the BAR. The impact on game viewing roads a conference and the person’s partner sharing assessed and feedback was provided to the accommodation might be driving around all attendees during the public meeting in the park? on 10 January 2015 (including Mr 2. Mr Fernsby wanted to know if Mr Kruger, the Fernsby). The traffic impact indicated archaeologist, is employed by SANParks. was calculated as a worst case scenario. 3. Mr Fernsby stated that there is a lack of trust This includes the impact of traffic during between the I&APs and SANParks due to past a fully booked lodge when there is no conference taking place (meaning more experience and meetings that would have cars on the road during day time) and been held to discuss certain issues that were also if all cars were to travel on the same cancelled by SANParks. road. 4. He stated that SANParks is over 2. Mr. Kruger is an independent consultant commercialising the KNP and the proposed employed by Exigo. development will make things worse. 3. Noted. The aim of the public meeting was to provide feedback regarding issues 5. Mr Fernsby wanted to know if the structures relevant to the proposed project in a were designed to be bat proof? transparent manner. 6. He stated that he is aware of past malpractices 4. Noted concerning the management of bats. 5. At the meeting Dr. Rautenback stated 7. Mr Fernsby stated that he had various that he was involved in various bat strategic planning concerns that he would like studies in the KNP and that he has had a to discuss. look at the lodge’s designs and that the design do not have ideal spots for bats to

roost. th At the public meeting on the 10 of January 2015 6. At the meeting Mr Schraader stated that Mr Fernsby had the following comments: he is unaware of any structure that is 8. He stated that he had seen a television entirely bat proof; but they are however programme with Oprah where it was stated improving designs continuously to keep that black people generally want to stay at bats out of buildings. SANParks further stated that they are unaware of any home, while white people wanted to go out poisoning of bats that have taken place (fish and camp). in the past. The KNP bat management 9. He recommended that SANParks should plan has been attached to EMPr. market the National Parks in townships in 7. It is proposed that a meeting be held

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order to create an appreciation for nature to between Mr Fernsby and SANParks the people living in the township areas. regarding strategic issues that fall 10. He stated that the impact that tourists have on outside the scope of this BAR.

the KNP extends further than the physical 8. Noted impact (e.g, roads). This includes the visual 9. At the meeting Mr Glen Phillips stated and noise impact. He stated that the impact that SANParks is active in the township would rather be in a 100m radius and that areas in this regard. weeds distributed could even have a much 10. Noted. As far as the proposed wider impact. development is concerned – it included 11. Impact of trenches on animals need to be impacts and management measures for noise, visual, traffic and weed managed management. 12. He stated that the amount of water abstracted 11. Mitigation measures in this regard have from the Sabie River should be monitored. been included in the EMPr. 13. Mr Fernsby again stated that there are various 12. At the meeting Mr Freek Venter stated in issues that he needs to discuss with SANParks. the meeting that the river is constantly measured and they know when it reaches the “worry” zones (periods of

low flow). 13. It is proposed that a meeting be held with Mr Fernsby regarding past issues that falls outside the scope of the BAR and public meeting. th Suzanne van Rooy [email protected] Email on the 19 th of Request for registration on 19 th of December 2014. Registered on the 19 of December 2014. th December 2014 On the 5 of January 2015 the EAP provide the communication on the review and public meeting Lowvelder Hanti Schrader Public meeting on the At the public meeting on the 10 th of January 2015 Environmental Journalist 10 th of January 2015 Me. Schrader had the following comments: Lowveld Media 1. Has the“Black diamonds” market been 1. Mr. Phillips stated in the meeting that SA [email protected] Tourism has done research in this regard and a researched anywhere in the country? lot of marketing is based on that. They have 2. Does SANParks want to attract the “Black however based it on the previous census diamonds”? figures, and now that a new census has been undertaken they would have to do new studies to put an exact figure to it. 2. This is the third market SANParks is trying to attract as indicated in the project motivation.

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Africa Wild Dewald du Plessis Public meeting on the At the public meeting on the 10 th of January 2015 Lynnette du Plessis 10 th of January 2015 Mr. du Plessis had the following comments: 1. Noted. At the meeting Mr Phillips stated 1. SANParks is projecting the problems of other that that the rest of the parks are not necessarily on the major tourist routes or do parks onto Kruger (Kruger has to fund the rest not have the charismatic species that would of the parks). attract as many visitors. He also mentioned 2. Haven’t Kruger reached a ‘full house’? that some of these parks are ecologically 3. If the Black Diamonds are emerging they don’t very sensitive and unique and therefore have to pursue them. They will visit the require protection just as much as the KNP. National Parks themselves. 2. Various research has been concluded, some by SA Tourism, Universities and internally. 4. The open game drive vehicles are creating a Internal surveys to SANParks’ current problem on the roads. There are too many customer base (mainly conducted by UNW) road users. do indicate that a lodge is not required and 5. How are the EAPs appointed? that the current visitor base are happy 6. The AIKONA questions are those of Africa Wild staying with the current self-catering as well. options, however, from a business 7. Will the lightning protection masts not create perspective, with occupancies of 88% in Skukuza, additional accommodation is a very large visual impact? required. As part of SANParks’ Responsible Tourism Strategy 2022, product diversification is a key component. 3. Noted. 4. Noted. Strategies are in process of being implemented to control/manage game drive vehicles. Aspects being looked at includes a performance management clause in contracts with these operators and SANParks is also considering installing a GPS system by which the movements of these vehicles can be tracked. 5. A tender process was followed. 6. Please refer to AIKONA response and in particular the letter attached to this report. 7. New lightning protection technology will be used that only has a limited height. The high masts relating to his concern are not the latest technology.

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Skukuza Safari Lodge: CRR

Africa Wild Ian Leach Public meeting on the At the public meeting on the 10 th of January 2015 10 th of January 2015 Mr. Leach had the following comments: Response at the public meeting: 1. He wanted to know whether the Stats SA 1. It includes all accommodation figures, however it is possible that only the information on the presentation was only corporate entities submit the based on high end accommodation. information to Stats SA. 2. He heard that the current concessions are 2. Occupancies are actually improving and struggling. for the first time now their occupancies 3. Can people that are not going to conferences are in the ‘60s’ (60 %). also stay in the lodge? 3. Yes. The bookings will be held for conferences until about 3 months before 4. He was concerned that if the laundry was and then opened up to the general outsourced it would lead to more traffic. public. 5. What is being done to ensure that the budget 4. In the meeting Mr. Phillips confirmed for the lodge does not increase that the laundry will be outsourced. He (overspending)? added that they are considering having the laundry outside of the camps as currently the laundry is driven between

the camps and by outsourcing this they might even reduce the traffic on the roads. 5. Mr Phillips said in the meeting that the state provided them with R240 000 000.00 and they manage the budget closely and that they normally keep well within their budgets. Landowner SANParks Danie Pienaar Email on 1 October Registered as representative of the landowner Registered Kruger National Park: Technical 2014 SANParks. Services, Private Bag X402, Skukuza The notification of the draft BAR and meeting Telephone: 013 735 4271 th was sent on 12 of Fax: 013 735 4051 November 2014 [email protected]

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Skukuza Safari Lodge: CRR

5. CONCLUSIONS

Public participation was adequately addressed during the Basic Environmental Impact Assessment (Basic Assessment) process for the proposed development. In order to facilitate an open and transparent process, I&AP’s were identified and notified of the proposed development, in accordance with the legislation. Comments/concerns received were incorporated and addressed in this Comments and Response Report and were mitigated for in the Basic Assessment Report (BAR). Assessing the comments/concerns received during the public participation process, it is evident that the main points are:

• Visual impact o Direct visual impact of lodge and impact from lightning masts o Light nuisance – in particular the impact on Tinga’s concessions as well as the Sabie Sands Game Reserve (Toulon and Kirkmans Camp in particular) • Noise nuisance o Noise impact on the rest camp, in particular the surrounding chalets • Lodge access times via the Kruger Gates and the possible associated impact on wildlife • Traffic Impact o Impact of additional traffic on access routes and game viewing roads • Ecological Impacts o Long term viability of the Stevenson Hamilton baobabs o Nuisance animal management o Impact of trenches on animals • Heritage Impacts o Impact on the Stevenson Hamilton baobabs • Socio-Economic impacts o Need for this type of development o Local employment benefits o Availability of bursaries and learnerships o Local décor and art should be used at the lodge in order to benefit local artists • Water use optimisation o Grey water usage o Monitoring water abstraction from the Sabie River • Other o Waste minimisation strategies o Electricity minimisation options o Increased environmental destruction and increased pollution including chemical pollution, combustion fumes and oil spills on roads.

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Skukuza Safari Lodge: CRR

o The EMP should be more stringent on the Applicant. o Reference should be made to the 20 Principles from the National Environmental Management Act (NEMA). o Concerns regarding over-commercialization and further lodges being built in the park. o Need for the lodge.

These concerns have been documented, answers provided where appropriate and those impacts requiring assessment have been undertaken and provided to the I&APS for review. Appropriate mitigation measures to address impacts were included in the BAR and EMPr.

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